In both the Record of Decision (ROD) and the Final Environmental Impact Statement (FEIS) for the New York/New Jersey/Philadelphia Airspace Redesign, the FAA states that there will be a decrease in emissions from aircraft as a result of the airspace redesign because the aircraft will burn less fuel. To support this theory, the FAA relies upon a cobbled-together "Fuel Burn Analysis" that is nowhere to be found in any of the FAA’s orders or procedures.
However, even with the ginned-up fuel burn analysis, it is now becoming apparent that there may be no savings in fuel to be derived from instituting the Airspace Redesign’s preferred alternative. Using the information provided in the Appendix R of the Final Environmental Impact Statement and the TAAM output files that were included in the Administrative Record as document 9285, Clean Air Act consultant Dan Meszler, of Meszler Engineering Services, concluded that the "Preferred Alternative" would seemingly increase fuel consumption.
On the following page is an excerpt from Mr. Meszler’s Report, along with a table showing the differences between fuel consumption reported in the FEIS and fuel consumption based on the TAAM data that was included in the Administrative Record.
EXCERPT FROM MESZLER ENGINEERING’S FEBRUARY 18, 2008 REPORT:
"There is no way to know whether [the files included in Administrative Record document 9285] are associated with an average demand day (consistent with the Appendix R fuel burn analysis) or a high demand day (consistent with the Airspace Redesign operational analysis). I assume that they reflect the latter, but they are still useful for evaluating the potential significance of the fuel burn corrections. Additionally, since most of the modeling scenarios reflected in the TAAM output files represent simulations of greater than 24 hours duration (some cover a period as long as 48 hours), I extracted TAAM fuel burn data for only the first 24 hours of each simulation. [The following table] presents the resulting data.
Estimated Aircraft Fuel Consumption (kg/day, unless otherwise specified)
|FEIS Appendix R Table 2.1 (Corrected)||24 Hour TAAM Output (High Capacity)||24 Hour TAAM Output (Low Capacity)|
|No Action 2011||IA w/ICC 2011||Benefit 2011||No Action 2011||IA w/ICC 2011||Benefit 2011||No Action 2011||IA w/ICC 2011||Benefit 2011|
1. The total fuel consumption in FEIS Appendix R Table 2.1 is reported to be 16,809,338 for the no action alternative and 16,661,646 for the IA with ICC alternative. These values erroneously exclude EWR and have been corrected for this table. The total reported benefits in FEIS Appendix R Table 2.1 were correct and are, therefore, unchanged in this table.
2. The gallons per day benefit reported in FEIS Appendix R is 66,840. The value reported in this table is marginally lower and the difference is undoubtedly the result of differing conversion factors. For this table, it was assumed that the density of aviation fuel was 6.8 pounds per gallon and that there are 2.2046 pounds per kilogram. The specific assumptions employed in FEIS Appendix R are not reported.
3. The TAAM data reported in this table are based on the only TAAM output files included in the Administrative Record. It is suspected that the files are for high demand scenarios (as opposed to average demand scenarios). The only adjustment made to the TAAM output is that only fuel consumption data for the first 24 hours of each TAAM scenario are considered. Since the context of these data in this evaluation are solely to demonstrate basic fuel consumption relationships and not absolute values, the use of high demand scenarios should be irrelevant.
4. Negative benefits signify a net increase in fuel consumption.
The first three data columns of the table simply reproduce the fuel burn data presented in Table 2 of Appendix R. As indicated, Appendix R estimates a modest fuel consumption decrease of just under 1 percent for the preferred IA w/ICC (Integrated Airspace with Integrated Control Center) alternative. This impact derives from the basic fuel consumption estimates of TAAM combined with EDMS and fuel-flow integrator adjustments. The next three data columns depict corresponding data derived from the high capacity runway configuration TAAM output files of Administrative Record document 92 85. The rightmost three data columns depict corresponding data derived from the low capacity runway configuration TAAM output files of Administrative Record document 9285.
The results indicate that the adjustments to the basic TAAM-estimated fuel consumption may provide the entire rationale for concluding that fuel consumption will be reduced under the preferred alternative. As indicated, the basic TAAM scenarios preduct fuel consumption increases of 1.1 percent under the high capacity runway configurations and 1.5 percent under the low capacity configurations. The predictions are directly consistent across all airports (i.e., all show increases), but are most pronounced at EWR, which accounts for 70-85 percent of the total change."